The Texas Health and Human Services Commission (“HHSC”) has established the “Medicaid Managed Care Aligning Technology by Linking Interoperable Systems for Member Health Outcomes Program” (ATLIS) under the authority of 42 C.F.R. 438.6(b)(2). Under this program, certain STAR, STAR Plus, and STAR Kids managed care organizations (“MCOs”) are eligible for incentive payments of up to 5% above their capitation for achieving milestones on various HHSC-designated quality metrics. Unified Network Initiatives of Texas LLC ("UNIT") provides comprehensive ATLIS program management services to MCOs with respect to ATLIS, resulting in UNIT serving as the go-between/facilitator with respect to ATLIS between MCOs and their participating hospitals. UNIT has developed a robust ATLIS-specific hospital network, allowing MCOs to access and leverage downstream contractual arrangements with UNIT Member Hospitals with respect to ATLIS activities.